Affordable Care Act 6055/6056 reporting for 2020

UnitedHealthcare will send 1095-B forms to fully insured plan subscribers prior to the Jan. 31, 2020, filing deadline. The forms will begin mailing in mid-December, 2019, and should be fully distributed by Jan. 31, 2020. 

Complying with 6055 requirements

Fully insured groups

Under the Affordable Care Act, employees with fully insured plans who were eligible for coverage for at least one month in 2019 must receive a 1095-B form from their insurance carrier. 

For fully insured customers, UnitedHealthcare sends the 1095-B forms directly to employees; they are not mailed to employers. Employers may not request forms for their employees or receive a report of employees who receive a form. 

If the member misplaces the form, they may obtain a copy of their 1095 on the myuhc.com® member site. They may also call the customer service phone number on the back of their health plan ID card. 

Fully insured Applicable Large Employers (ALE) with 50+ full-time equivalent (FTE) employees must also send their employees a 1095-C.

Self-funded groups

Self-funded (ASO) customers must provide their employees, by Jan. 31, 2020, with a 1095-B if they are a small employer with one to 49 FTEs, or with a 1095-C if they are an ALE with 50 or more FTEs.

Complying with the IRS information reporting requirements

The following forms must be transmitted to the IRS by Feb. 29, 2020, if filing by paper, or by March 31, 2020, if filing electronically: 

  • 1094-B Transmittal of Health Coverage
  • 1095-B Health Coverage
  • 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
  • 1095-C Employer-Provided Health Insurance Offer and Coverage

Note: Employers with 49 or fewer FTEs are not required to submit a report to the IRS.

New state requirements for individual coverage and associated reporting requirements

Individuals are no longer subject to a federal Internal Revenue Service (IRS) penalty if they did not comply with the shared responsibility requirements of the Affordable Care Act (ACA), sometimes referred to as the Individual Mandate. The penalties have been removed for those who do not have health insurance coverage. However, some states have initiated their own individual mandate requirement for residents of those states. 

New: New Jersey and D.C. implemented state individual mandate requirement for 2019

Although the federal level penalties have been removed for those who do not have health insurance coverage, some states have initiated their own individual mandate requirement for residents of those states. 

Individuals who have resided in New Jersey or Washington, D.C., for any time during 2019 will be required to report if and when they had minimum essential coverage (MEC) on their 2020 New Jersey or D.C. tax returns. 

UnitedHealthcare will submit the required 1095 forms to the state tax departments by the deadlines below for fully insured groups:

  • New Jersey Tax Department: By March 31, 2020
  • Washington, D.C., Tax Department: By June 30, 2020

In addition, fully insured ALEs and self-funded groups will be required to submit copies of either the 1095-B (groups 1 to 50 FTE) or 1095-C (50+ FTE) to the state of New Jersey or D.C. tax departments. 

There are penalties for individuals who have resided in New Jersey or D.C. beginning with the 2019 calendar year if they do not have insurance coverage as required by the state. 

If needed, a self-funded group may request a custom eligibility report to include month by month coverage that is available for a fee. The group may also request a report for either the New Jersey or D.C. residents. For 2020, the report will include current residence only.

Several other states have indicated that they have legislation adding an individual mandate and penalty for 2020 that will require reporting in 2021. UnitedHealthcare will send out information as the states approve the legislation.  

Summary of UnitedHealthcare’s approach

For fully insured groups: UnitedHealthcare will send the 1095 form to subscribers, to the IRS and where required to the NJ or DC state tax department by the due dates.

For fully insured ALEs: The group is required to send the IRS 1095-C forms and where required send to the NJ or DC state tax department by the due dates.

For All Savers®: All Savers will provide eligible small groups* with populated Forms 1095-B an employer can distribute to their employees. In addition, All Savers provides small groups with a Membership Report that details their employees and coverage months throughout the current tax year. This data can be used to prepare 1095-C forms which are required if group is 50 or larger. The group must be submit the report to the IRS and, as appropriate, to NJ or DC state tax department by the due dates.

For large self-funded groups: The customer prepares the 1095-C form, which they then submit to subscribers, to the IRS and where required to the NJ or DC tax departments by the due dates. 

As additional guidance is released it will be shared. Contact your UnitedHealthcare representative with questions.